CONFEDERATED TRIBES OF THE UMATILLA INDIAN
RESERVATION
From: LisaBreckenridge [mailto:breck@ctuir.com]
Sent: Thursday, September 16, 2004 3:02 PM
To: Comments
Cc: BarbaraRoloff; LisaGanuelas
Subject: Community Reinvestment -- RIN 3064-AC50
The Confederated Tribes of the Umatilla Indian Reservation Department
of Economic and Community Development opposes the FDIC's proposal to
allow banks with assets above $250 million to be examined as small banks
under the Community Reinvestment Act (CRA). This policy would reduce
lending, investments and services in low-income communities such as the
Umatilla Indian Reservation. We have been working hard to reduce
poverty, increase homeownership, foster financial literacy, and help
tribal members build assets, and the lending community through CRA has
been a very important partner in this effort. The existing CRA has been
positive for low-income communities as stronger relationships have been
built between lenders and low-income borrowers than ever before. The
proposed redefinition will reduce bank accountability to rural and
low-income communities. It is actually a step backward. Please maintain
the current definition of small banks under the CRA and allow the
positive results of CRA to continue to grow.
Lisa Breckenridge
Economic Planner
Confederated Tribes of the Umatilla Indian Reservation
P.O. Box 638
Pendleton, OR 97801
ph. 541.966-2193
f. 541.276.3262
